Provide a narrative description of the purpose of the project.
Response
Turtle is capital coordination infrastructure for internet capital markets. The protocol connects asset issuers to a verified network of onchain liquidity providers and handles the full path between them: deal sourcing, due diligence, incentive distribution, billing, and liquidity provider relationship management, with capital flows attributable and verifiable onchain.
For each existing entity: Labs/DevCo (e.g., Founder, CEO, CTO, COO), Foundation (e.g., President, Executive Director, CFO, COO), and DAO / onchain governance leadership (if applicable) list the:
For any non-existent entity, explicitly mention it does not exist. External links may be included but they will not factor into the score.
Response
Full Name | Official Title | Prior Experience |
|---|---|---|
does not exist |
Full Name | Official Title | Prior Experience |
|---|---|---|
Esfandiar (Essi) Lagevardi | President of the Board (Chairperson, individual signing authority); CEO & Co-Founder | CFO at Omniscia (smart contract audit firm, 2021-2024); Director of DeFi at W3BCLOUD; Aston Business School |
Nicholas Jeffrey Thoma | Member of the Board (joint signature, any two to sign); CTO & Co-Founder | ParaFi Capital, Brain Corp, NASA |
Connor Milner | CBDO | RE7 Capital |
Waseem Shabout | COO (Operations and Diligence) | Arkham, Celsius |
Tim Haldorsson | CMO; CEO of Lunar Strategy (business unit of the Association) | Founder of Lunar Strategy |
Full Name | Official Title | Prior Experience |
|---|---|---|
does not exist | No separate DAO governance leadership exists. On-chain governance is exercised directly by sTURTLE holders through the OpenZeppelin Governor contract; all officers are Turtle.Club Association staff and are listed under Foundation above. | Not applicable |
Provide a structured description of the DAO's governance, powers, and economic rights. If a DAO does not exist, state so for each sub question. Even if there is no DAO, there must be an answer to (d). Address the lettered items below.
Response
No for-profit development company exists, and no entity with equity shareholders claims rights to the protocol. Intellectual property is held and administered by the Turtle Club Association (a Swiss Verein based in Zug, with no equity shareholders), solely to execute decisions approved by the DAO. This covers the protocol codebase, developed by contributors engaged under the Association's Master Token Incentive Plan (TMTIP), and the Turtle brand and domains. The protocol repositories are proprietary; public transparency data (per-address airdrop allocations) is published under the turtle-dao GitHub organization (github.com/turtle-dao/turtle-transparency) without a separate open-source license. The Association also holds the Lunar Strategy brand and business: Lunar Strategy, a marketing and go-to-market business acquired in June 2026 (publicly announced 2026-07-22), operates as a business unit of Turtle inside the Turtle Club Association, not as a separate legal entity, so its brand, client contracts and economic value sit within the Association for the benefit of the DAO.
DAO Treasury Multisig, 0x2e0355922EF3a5b77d29287C808aEafB4e7f25B2 (Ethereum and BSC, same address and signer set). Gnosis Safe v1.4.1 with a 3-of-5 signing threshold; five signers comprising core team members and independent parties; no modules or guard contracts are enabled. Holds the unallocated Ecosystem and Community allocation. Method of authority: 3-of-5 signature execution of governance-approved actions. Limits: no on-chain timelock, veto or guard; its authority is bounded off-chain by the Association's Articles of Association (the Board manages the Association's assets and implements DAO resolutions, Articles 12 and 23) and by the standing rule that every treasury outflow requires governance approval.d contracts are enabled. Holds the unallocated Ecosystem and Community allocation. Method of authority: 3-of-5 signature execution of governance-approved actions. Limits: no on-chain timelock, veto or guard; its authority is bounded off-chain by the Association's Articles of Association (the Board manages the Association's assets and implements DAO resolutions, Articles 12 and 23) and by the standing rule that every treasury outflow requires governance approval.
Off-chain governance approval standard: pending activation of the deployed Governor contract, DAO-approved actions are authorized by resolution of the board of the Turtle Club Association, acting on token holder signal, and executed by the 3-of-5 Treasury Multisig.
Governor contract (OpenZeppelin Governor), 0x27cbB991EfF5E5c7b6734675E837EDDF924Ffece (Ethereum). Deployed, not yet active. Parameters: proposal threshold 1.5M sTURTLE, quorum 4%, voting delay 4 days, voting period 2 weeks. Method of authority once active: token-weighted majority of sTURTLE votes cast, subject to quorum. Executor powers once active: a passed proposal authorizes the Association's Board to execute the approved action, with on-chain treasury movements executed through the 3-of-5 Treasury Multisig; no timelock is configured. Limits: the Governor holds no authority over the TURTLE token contract (immutable, no mint or pause), cannot change the fixed supply, and cannot deviate from the TMTIP standard vesting schedule without the separate supermajority (66%) token holder vote.
TURTLE token contract, 0x66fd8de541c0594b4dccdfc13bf3a390e50d3afd (Ethereum and BSC). Immutable ERC-20: no mint function, no pause role, no admin key. No authority exists over this contract.
Rewards distribution contract, 0x56aa6D651bfefA9207B35E508716466359BAe8eF (BSC). Owned by the 3-of-5 DAO Treasury Multisig; method of authority: 3-of-5 signature execution of governance-approved actions.
Staking contract (sTURTLE), 0x2d362158034EEB28e1a7062F24FfC436b1D01858 (Ethereum). Upgradeable proxy governed by an on-chain access manager (OpenZeppelin AccessManager, itself an upgradeable proxy) at 0xD5e4ac485F09eE907F5dD8b9a9935a09875f7bFb. Admin authority over the manager is held by a single address, 0xaed8FCC3B124E754D4a8Def82f2CA579b4370058 (Turtle Access Admin), an operator-controlled wallet held in Utila MPC custody by the Turtle Club Association; it is not a DAO multisig and not the deployer, and no other address holds the admin role. Method of authority: transactions submitted directly from that wallet, signed through Utila MPC custody under a policy requiring approval by at least one additional Utila administrator (all four authorised approvers are Association personnel); this control is enforced at the custody layer, not as an on-chain signing threshold, and transactions execute immediately with no on-chain timelock. Limits: the admin role controls the staking contract's privileged functions (setting the redeem delay, pausing and unpausing, rescuing unclaimed redeem requests, and authorising contract upgrades), with protections enforced in the contract itself: a pause suspends deposits and mints only, leaving redemption requests and claims available so holders can always exit, and unclaimed redeem requests can be rescued only after 365 days past their unlock timestamp.
Sablier vesting streams: the Association may cancel a stream solely under the TMTIP leaver provisions. Method of authority: a resolution of the Association's Board, passed by simple majority of Board members present with the President holding the casting vote (Articles 11 and 12 of the Articles of Association), determining good-leaver or bad-leaver status; the cancellation transaction is then submitted by the Association's authorised signatories. No other person can cancel a stream, no other ground for cancellation exists, and any deviation from the standard vesting schedule requires a supermajority (66%) token holder vote.
Bridge pools: controlled by Chainlink CCIP; Turtle holds no unilateral bridge authority.
A locking mechanism exists. TURTLE holders stake TURTLE to receive sTURTLE, which carries governance voting power; unstaked TURTLE carries no voting rights. sTURTLE holders can decide: treasury allocations and outflows, protocol parameters and upgrades, strategic initiatives, distributions from the Ecosystem Growth allocation, and, by supermajority, deviations from the standard vesting schedule and any new token launch. sTURTLE holders cannot: compel dividend-style distributions to holders (no such mechanism exists), direct the Turtle Club Association beyond the execution of DAO-approved decisions, or alter the fixed token supply without a quorum-based governance vote. Tokens locked in vesting contracts (team, investors, advisors) cannot be staked, carry no voting power, and earn no staking rewards until vested and claimed.
Governance is currently conducted off-chain by sTURTLE holders, with approved outcomes executed by the Turtle Club Association and the DAO Treasury Multisig. Presently operative arrangements:
Treasury actions: all treasury outflows require governance approval and are executed by the DAO Multisig. Distributions from the Ecosystem Growth allocation are disclosed publicly at least 7 days in advance, including recipient category, amount, vesting terms, and rationale.
Fee routing: all protocol inflows (boost payments, vault performance and AUM fees, campaign revenues, curation and transaction fee shares) flow directly to the DAO-controlled treasury. No fee share is routed to any equity holder or off-chain entity beyond Association operating expenses approved by the DAO.
Rewards: staking rewards accrue to non-insider sTURTLE stakers; unvested insider allocations are excluded.
Buybacks: no standing buyback or token-repurchase program operates. No dividends or direct distributions to token holders currently operate; value accrues to the DAO treasury, which token holders govern. Lunar Strategy, the marketing and go-to-market business acquired in June 2026, operates as a business unit inside the Turtle Club Association rather than as a separate legal entity; its revenue and costs form part of the Association's accounts, and its economic value accrues to the DAO as the Association's beneficiary.
The protocol anticipates transitioning voting on-chain. An OpenZeppelin Governor contract is already deployed (proposal threshold 1.5M sTURTLE, quorum 4%, voting delay 4 days, voting period 2 weeks) and will assume active use when the protocol activates on-chain governance. The intended end state is a hybrid model: binding on-chain votes by sTURTLE holders, with the Turtle Club Association executing off-chain actions (legal agreements, treasury transfers) strictly as directed by vote outcomes. No changes to the fixed supply, the absence of a DevCo, or the routing of protocol inflows to the DAO treasury are anticipated as part of this transition. No firm activation date is committed; activation will be announced through official channels.
The DAO's off-chain wrapper is the Turtle Club Association, a Swiss Verein domiciled in Zug (founded 12 July 2024, entered in the Commercial Register of the Canton of Zug, UID CHE-258.098.477). Under its Articles of Association, dissolution is decided by the General Meeting of members with a majority of three quarters (75%) of the members present (Articles 9 and 24); the same 75% threshold applies to amendments of the Articles. If dissolution is resolved, the Board carries out the liquidation unless the General Meeting appoints special liquidators (Article 24). Net assets remaining after payment of all debts and other obligations may be distributed to the members of the Association (Article 25); membership is a single class admitted at the Board's discretion, with one vote per member and a membership fee of CHF 0. The Association may also be dissolved by operation of law under Articles 76 et seq. of the Swiss Civil Code (insolvency, or a court finding its purpose unlawful). Under Article 23 of the Articles, DAO resolutions are proposals to the Association which the General Meeting or the Board implements unless implementation lacks funding, contradicts the Association's purpose, breaches Swiss or foreign law, or creates other risk for the Association. A wind-up of the DAO treasury itself is a treasury action: it requires sTURTLE holder approval under the standard governance process (proposal threshold 1.5M sTURTLE, quorum 4%, token-weighted majority of votes cast) and execution by the 3-of-5 DAO Treasury Multisig, with any related legal steps resolved by the Association's Board.
For the Primary Foundation do the following independently. If a Foundation does not exist, state so for each sub question. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist. Definition: The primary Foundation can be explained as the entity which was directly/indirectly involved in the issuance of the native token at launch. If the original Foundation has been dissolved and in its place a "new Foundation" was created, then detail the "new Foundation".
Response
Entity: Turtle Club Association, a Swiss Verein (association under Articles 60 et seq. of the Swiss Civil Code) with its seat at Gotthardstrasse 26, 6300 Zug, Switzerland, UID CHE-258.098.477. Founded on 12 July 2024 and entered in the Commercial Register of the Canton of Zug (application filed 15 July 2024). Non-profit under Article 3 of its Articles of Association; no equity and no shareholders. Its bodies are the General Meeting of members (one vote per member) and a Board of at least two members elected for one-year terms. Board as registered: Esfandiar Lagevardi (President, sole signing authority), Felix Frisk (member, joint signature at two), Caspar Sauter (member, sole signing authority). No auditor is appointed because the thresholds of Article 69b of the Swiss Civil Code are not met. It was the entity directly involved in the issuance of TURTLE at TGE (October 22, 2025).
IP: the Association holds and administers the protocol codebase IP, the Turtle brand and domains, and the Lunar Strategy brand and business unit, solely to execute DAO-approved decisions. Article 3 of its Articles of Association expressly permits the Association to hold participations in other companies, to acquire, exploit, administer and dispose of tokens and intellectual property rights, and to establish subsidiaries and branch offices in Switzerland and abroad; the protocol IP and the Lunar Strategy business unit are held under that authority. Lunar Strategy is not a separate legal entity. The protocol repositories are proprietary. Public transparency data (per-address airdrop allocations) is published under the turtle-dao GitHub organization (github.com/turtle-dao/turtle-transparency) without a separate open-source license.
The Foundation (Turtle Club Association) holds the following powers, each with its method of exercise; it holds no others.
Treasury: no unilateral power. Treasury outflows require DAO governance approval and execute through the DAO Treasury Multisig with a 3-of-5 signature threshold; the signer set includes core team members and independent parties.
Protocol revenue: no power to redirect. All protocol inflows (boost payments, vault fees, campaign revenues, curation and transaction fee shares) route to the DAO treasury by default; the Association cannot capture or redirect revenue to itself beyond DAO-approved operating funding (see (f)).
Reward parameters: none. Incentive campaign parameters (rates, durations, eligibility) are configured by the partner protocols running each campaign, within the protocol's rules; the Association does not set or alter reward parameters on live campaigns.
Token administration: the token contract is immutable (no mint, no pause), so no administration power exists over supply. The Association administers the TMTIP vesting plan; method: Association board action strictly bounded by the plan's terms, limited to (i) issuing grants on the standard 12-month-cliff/36-month-linear schedule and (ii) cancelling Sablier streams solely upon a board determination of leaver status under the plan's leaver provisions. Any deviation from the standard schedule requires a supermajority (66%) token holder vote, which the Association cannot waive.
Market maker lending: the Association acts as lender of record for the three market maker token loans. Method: the Association executes each loan agreement as a DAO-approved action; the loaned tokens (aggregate 22,500,000 TURTLE, 2.25% of supply) are drawn from the Liquidity, MM & Exchange reserve and released via the 3-of-5 Treasury Multisig.
Powers over DevCo: no DevCo exists.
Pause authority: none. The TURTLE token contract has no pause function on any chain, and the Association holds no pause keys over any token-related contract.
Upgrade authority: none held directly on-chain. The one upgradeable token-related contract (the sTURTLE staking proxy) is governed by an on-chain access manager at 0xD5e4ac485F09eE907F5dD8b9a9935a09875f7bFb, whose admin is a single operator-controlled wallet (Turtle Access Admin, 0xaed8FCC3B124E754D4a8Def82f2CA579b4370058) held in Utila MPC custody. The Association holds an indirect role in that process: the Utila custody account through which the admin wallet operates is held by the Turtle Club Association, all four authorised approvers are Association personnel, and the Association designates those approvers. The Association therefore participates indirectly in staking contract upgrade and admin actions through its control of the custody account, while holding no direct on-chain admin key. Approval threshold within the Utila custody account: 3 of the 4 authorised approvers.
Governance-executor authority: yes. The Association executes DAO-approved decisions off-chain (legal agreements, treasury transfers). Method: an Association board resolution implementing the approved outcome, with any on-chain movement executed through the 3-of-5 DAO Treasury Multisig. The Association cannot originate treasury actions without governance approval.
Vesting stream administration: the Association may cancel a Sablier vesting stream solely under the TMTIP leaver provisions. Method: board determination of good-leaver or bad-leaver status per the plan; no other modification authority exists, and schedule deviations require a supermajority (66%) token holder vote.
Association signing authority per the Commercial Register of the Canton of Zug: the President (Esfandiar Lagevardi) signs alone, one Board member (Caspar Sauter) signs alone, and one Board member (Felix Frisk) signs jointly with a second signatory. Board resolutions pass by simple majority of members present with the President holding the casting vote, and may be taken by circular resolution unless a member requests a meeting (Articles 11 and 12 of the Articles of Association). No on-chain timelock applies to any authority listed above.
Authorizing mechanism: the Association's funding is authorized through DAO governance-approved treasury resolutions, under the standing arrangement disclosed in Section 3(d) that every treasury outflow requires governance approval; approved amounts are released by the 3-of-5 Treasury Multisig. Distributions from the Ecosystem Growth allocation additionally follow a programmatic disclosure rule: public notice at least 7 days before distribution, stating recipient category, amount, vesting terms, and rationale.
Recipients: resources flow to (i) the Association itself, strictly for operating expenses (legal, compliance, treasury management, infrastructure); (ii) core contributors and independent contractors, as TURTLE grants under the TMTIP, streamed via Sablier on the standard vesting schedule; (iii) external advisors and service providers, from the 16M TURTLE Advisor Allocation; and (iv) ecosystem participants, via governance-approved Ecosystem Growth distributions and campaign incentives. No resources flow to equity holders (none exist), and no direct distributions flow to token holders.
For the Primary DevCo do the following independently. If an entity does not exist, state that explicitly across each sub-question. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist. Definition: The primary DevCo can be explained as the entity which was directly/indirectly involved in the issuance of the native token at launch. If the original DevCo has been dissolved and in its place a "new DevCo" was created, then detail the "new DevCo".
Response
No DevCo exists. No for-profit development company was directly or indirectly involved in the issuance of TURTLE at launch, none has been dissolved or replaced, and none exists today.
Not applicable; no DevCo exists. No development company owns or controls any protocol IP, codebase, or brand.
Not applicable; no DevCo exists and no such entity holds any power over the DAO, treasury, protocol-controlled resources, or token administration.
Not applicable; no DevCo exists and no entity holds powers over the Turtle Club Association other than its own governing bodies.
Not applicable; no DevCo exists and no development company holds pause, upgrade, or executor authority over any contract.
Not applicable; no DevCo exists. No protocol cash flows are or can be directed to development-company equity holders, as no such entity or equity exists.
Definition (for this section): An Affiliated Protocol Contributor (APC) is a non-issuer company - not the protocol's primary Foundation or DevCo - that materially contributes to the protocol's code, operations, governance, or funding. For example, Blockworks Advisory would be considered an APC of Ethena because it materially contributes to its operations through Ethena's risk council. Provide a structured description per APC. If no APCs exist, state that explicitly across each sub-question. Items below apply per APC.
Response
One Affiliated Protocol Contributor exists: Lunar Strategy. Lunar Strategy is a brand and business unit of Turtle and not a separate legal entity, so its identity fields are those of the entity that operates it. Legal name: Turtle Club Association. Entity type: Swiss Verein (association under Articles 60 et seq. of the Swiss Civil Code). Jurisdiction: Zug, Switzerland, UID CHE-258.098.477. Role: marketing, communications, go-to-market and events for the protocol and its partner protocols, run as a separately managed P&L inside the Association since the Lunar Strategy business was acquired in June 2026 (publicly announced 22 July 2026). The market makers disclosed in the Market Maker Agreements section are counterparties under token loan agreements, not protocol contributors, and are not Affiliated Protocol Contributors. No other APC exists.
Lunar Strategy holds no control over protocol parameters, contracts, or governance; its scope is limited to marketing, communications and go-to-market services. No other APC exists.
None. Lunar Strategy holds no keys, no multisig seats in its business-unit capacity, and no pause, upgrade, or governance-executor authority over any protocol contract. No other APC exists.
Lunar Strategy is a business unit inside the Turtle Club Association, so no protocol resources are routed to any third party. Source: its operating costs (staff, tooling, events) are paid from the Association's operating budget, which is funded from the DAO treasury under governance-approved treasury resolutions. Routing mechanism: approved amounts are released by the 3-of-5 DAO Treasury Multisig to the Association's operating accounts. Frequency: ongoing, settled through the Association's regular operating cycle. Duration: for as long as the business unit operates, with no fixed end date. Revenue: client fees earned by Lunar Strategy are received by the Association and accrue to the DAO as the Association's beneficiary. No token allocation, revenue share, fee routing or other protocol-linked economics are routed to Lunar Strategy beyond that operating budget; individual contributors may receive TURTLE grants under the TMTIP, disclosed in the Vesting Insider Tokens section. No other APC exists.
Response
Ticker | Date | Allocation Category Name | Recipient Type | Allocation % | Allocation Tokens | TGE Unlock % | TGE Unlock Tokens | Cliff Months | Cliff Unlock % | Linear Vesting Months | Cadence Months | Circulating Treatment | Notes on what each category is used for | If applicable: Contract / Wallet address |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
TURTLE | 2025-10-22 | Ecosystem & Community | Ecosystem | 0.293 | 293000000 | 0 | 0 | 0 | 0 | 0 | 0 | Conditional | Unallocated ecosystem and community reserve held in the DAO Treasury Multisig; distributions require token holder governance approval with 7-day public notice. Source: docs.turtle.xyz/transparency (B-2 filing, April 2026) | 0x2e0355922EF3a5b77d29287C808aEafB4e7f25B2 |
TURTLE | 2025-10-22 | Private Rounds (Investors) | Private / VC | 0.275 | 275000000 |
If there are no post-TGE token compensation plans, state explicitly they do not exist across each sub-question. If there are, explain each of (a)–(b) below.
Response
Post-TGE token compensation exists and is governed by the same plan as founding-team grants: the Turtle Master Token Incentive Plan (TMTIP), drawing from the Team, Advisors & Contributors allocation (23.10% of total supply). Tokens currently locked and attributable specifically to employees and contractors hired after TGE (October 22, 2025) total approximately 55,000,000 TURTLE, approximately 5.5% of total supply. All such tokens remain locked under the standard schedule and cannot be staked or voted until vested and claimed.
Post-TGE hires receive grants on the identical Standard Schedule applied to founding contributors, with no separate or discounted plan: total duration 48 months, a mandatory 12-month cliff, then linear vesting over 36 months, streamed continuously via Sablier contracts for on-chain verifiability. The Vesting Commencement Date for post-TGE hires is set to the TGE date (October 22, 2025) rather than the hire date, aligning all unlock timelines to a single schedule; the practical effect is that a later hire's effective cliff from their start date is shorter than 12 months, while their total lock still ends no earlier than any founding contributor's. Signing bonuses in unlocked tokens, cliffs under 12 months, and schedules under 4 years are prohibited; any deviation requires a supermajority (66%) vote of token holders. Bad-leaver termination forfeits 100% of unvested and vested-but-unclaimed tokens to the treasury; good leavers retain vested tokens only.
Disclose current token-based compensation for external advisors and service providers (e.g., legal, marketing, technical, growth) funded from the on-chain treasury. Do not disclose individual payments to advisors receiving fiat-only compensation. If there are no advisors contracted in tokens then state across each sub-question that no token-based advisory compensation exists.
Response
Token-based advisory compensation exists. External advisors providing strategic, technical, and legal services are compensated exclusively in TURTLE token allocations; no fiat payments and no revenue-sharing arrangements exist for advisors. Advisors receiving fiat-only compensation: none.
A total of 13,000,000 TURTLE (1.3% of total supply) is currently outstanding for advisory services, from the dedicated Advisor Allocation pool within the Team, Advisors & Contributors allocation. The pool originally comprised 16,000,000 TURTLE across strategic, technical, and legal advisors; 2,000,000 TURTLE was subsequently repurchased from one advisor by the treasury, and approximately 1,000,000 TURTLE was cancelled following the termination of an advisory relationship, leaving 13,000,000 TURTLE outstanding. This is the aggregate across all existing token-based advisory services. All advisor allocations are subject to the standard vesting schedule and cannot be staked or voted until vested and claimed.
The Turtle Club Association (Swiss Verein, Zug), via the dedicated Advisor Allocation pool defined in the tokenomics. Grants are streamed through Sablier vesting contracts, released per the standard schedule; the Association administers the streams and may cancel them solely under the TMTIP leaver provisions.
Three service categories, each with its allocation:
Disclose ongoing KOL/influencer relationships that partially or fully received tokens for payment. You do not need to disclose KOL/influencers that do not receive tokens for payment. If no KOL engagements exist, state for each sub-question that no KOL engagements exist.
Response
No KOLs or influencers receive TURTLE tokens as payment, in whole or in part, and no token-paid KOL engagements have existed since TGE. Turtle's creator-facing program is deliberately structured as the alternative to token-paid KOL marketing: distributors are compensated through deposit-based revenue share on verified deposits they route to opportunities, settled outside the native token, with no TURTLE grants attached to promotion. No token-paid engagements were inherited through the Lunar Strategy acquisition.
Not applicable; no KOL or influencer receives tokens for payment, so there are no usernames or roles to disclose.
Not applicable; zero tokens are allocated to KOL or influencer engagements, and no vesting or lock arrangements of this kind exist.
For each wallet that holds Unissued Tokens or is essential to operations (e.g., foundation, operations, treasury, investor reserve), disclose:
Definition: Unissued Supply = tokens authorized by the contract but not yet issued to any party; where they sit (treasury or mint authority) does not change that they are unissued. For instance: if a token has a total supply cap of 1B, and 400M tokens have been issued to investors, the team, and users (whether vested or unlocked), then those 400M count as issued supply. The remaining 600M are authorized but unissued supply, even if they are already minted into a DAO treasury wallet.
Response
Title | Primary Function | Chain | Address | Control Mechanism | Explorer Link |
|---|---|---|---|---|---|
DAO Treasury Multisig | Holds the unallocated Ecosystem & Community allocation; executes governance-approved treasury outflows | Ethereum & BSC (same address) |
Projects must disclose all material terms of market-making arrangements that affect token liquidity. If the project has no agreements or deals with market makers, state that explicitly. For each market maker, include in a table:
If no native tokens were loaned or allocated to market makers, state that explicitly; cash/fiat retainers or fees are not required for (b).
Response
Market Maker Name | Token Allocation Committed | Term Duration | Structure Name |
|---|---|---|---|
Laser Digital (Nomura) | 7,500,000 TURTLE (0.75% of total supply), fully delivered in three tranches of 2,500,000; final tranche delivered May 5, 2026 | 18 months | Token loan |
GSR Markets | 7,500,000 TURTLE (0.75% of total supply), fully unlocked at TGE. Part of the 22,500,000 TURTLE aggregate committed across the three token-loan counterparties. | 18 months | Token loan |
FalconX | 7,500,000 TURTLE (0.75% of total supply), fully unlocked at TGE. Part of the 22,500,000 TURTLE aggregate committed across the three token-loan counterparties. | 12 months | Token loan |
Projects must disclose all material terms of centralized or decentralized exchange listings that affect token liquidity. For each listing, include in a table:
If the project has no agreements or deals with CEX or DEX, state that explicitly; doing so earns full credit; cash/fiat fee amounts are not required for this item.
Response
Exchange Name | Token Allocation Committed | Term Duration | Native Token Listing Fees |
|---|---|---|---|
Binance (via Binance Alpha) | None; no TURTLE tokens were allocated to Binance in connection with this listing | Listed October 22, 2025 via Binance Alpha, a discovery platform for early-stage tokens; no formal listing agreement, lockup, or incentive program | None; no listing fee was paid in native tokens or otherwise |
If a category does not exist or is not applicable, make that clear in plain language.
Response
No token repurchase program and no secondary-market accumulation strategy exists. The single exception is a one-off, treasury-funded repurchase of 2,000,000 TURTLE from one advisor, disclosed in the Token Advisory Billings section. Source of funds: the DAO treasury. Treatment: treasury retention; the tokens are held by the treasury and have not been burned. Policy controller: any repurchase or secondary-market accumulation is a treasury action that requires DAO governance approval and is executed by the Board of the Turtle Club Association, which manages the Association's assets and implements DAO resolutions under Articles 12 and 23 of its Articles of Association, through the 3-of-5 DAO Treasury Multisig; no standing mandate or discretionary buyback authority exists, and the Association cannot originate such a transaction without governance approval. Re-use: the repurchased tokens are not permanently removed from circulation; they may be re-issued or redistributed only through a governance-approved distribution, subject to the 7-day advance public disclosure rule that applies to treasury distributions. No open-market buybacks have been conducted.
Protocol-owned liquidity exists. Turtle's protocol-owned liquidity is deployed in a single venue: the TURTLE/USDC 0.30% fee-tier pool on Uniswap v4 (Ethereum), which is the protocol's primary onchain market for TURTLE.
Size: approximately USD 1.4 million of total value locked as of 23 September 2026. The full liquidity of that pool is protocol-owned. Four further TURTLE pools exist on Ethereum with combined total value locked below USD 9,000 (TURTLE/ETH, TURTLE/USDT, and two additional TURTLE/USDC and TURTLE/ETH fee tiers); these are immaterial.
Disclose all prior token sales by the Project — including fundraising rounds, any material OTC sales to investors, and any discounted market-maker sales. For each sale, provide:
If no prior sales occurred, state that explicitly (e.g., "No prior fundraising, OTC, or discounted MM sales have occurred.").
Response
Series Name | Investment Instrument | Date Of Sale | Number of tokens sold | Vesting Schedule |
|---|---|---|---|---|
Pre-Seed | SAFT | FEBRUARY 2024 | 55800000 | 6 months cliff, 36 months linear; cliff runs from TGE, 2025-10-22 |
Seed | SAFT | AUGUST 2024 | 107500000 | 6 months cliff, 36 months linear; cliff runs from TGE, 2025-10-22 |
Strategic | SAFT | OCTOBER 2025 | 91700000 | 6 months cliff, 36 months linear; cliff runs from TGE, 2025-10-22 |
Anchor LP Distribution | Token distribution agreement (anchor LP program) | APRIL 2024 | 20000000 | 6 months cliff, 36 months linear; cliff runs from TGE, 2025-10-22 |
Provide a narrative description of the Project's material funding sources, economic flows, and operational provisioning, broken out by entity: Foundation, Lab/DevCo, and DAO. If an entity does not exist, state that explicitly.
Response
Foundation: exists. The Turtle Club Association, a Swiss Verein domiciled in Zug, with no equity shareholders. Lab/DevCo: does not exist; no for-profit development company exists or was involved in token issuance. DAO: exists, comprising TURTLE token holders, with voting power exercised through staked sTURTLE.
DAO: all protocol-generated inflows route to the DAO treasury: boost payments negotiated from partner protocols for routed liquidity; performance and AUM fees on vault products; ecosystem campaign revenue from partner chains and foundations for structuring and bootstrapping liquidity; curation and transaction fee shares from the liquidity layer; and yield earned on treasury assets. The treasury also holds proceeds from the prior fundraising rounds disclosed in Prior Token Sales & Fundraising.
Foundation: the Association has no independent revenue source; it is funded from the DAO treasury and protocol inflows strictly to cover operating expenses, under governance-approved treasury resolutions executed by the 3-of-5 Treasury Multisig.
Lab/DevCo: not applicable; no such entity exists to receive funding.
If any, list prior exploits or incidents that directly affected the token, token supply, tokenholder balances, token contract, minting controls, burn mechanics, or custody of token supply. This question is not asking about general protocol, application, or smart contract exploits unless the incident directly affected the native token itself. If no prior incidents, state this explicitly (e.g., "No exploits affecting tokenholders or protocol funds as of YYYY-MM-DD").
Response
No exploits or incidents affecting the TURTLE token have occurred as of 2026-08-25. This covers the token contract on all chains (Ethereum, BSC, Linea), token supply, tokenholder balances, minting controls (none exist; the contract is immutable with no mint function), burn mechanics, and custody of token supply, none of which have been affected by any incident since TGE (October 22, 2025).
No exploits or incidents affecting the native token have occurred as of 2026-08-25. There is therefore no exploit vector to summarize: the token contract (Ethereum, BSC, Linea) is immutable with no mint or pause functions, and no incident has affected token supply, tokenholder balances, or custody of token supply since TGE (October 22, 2025).
Not applicable; zero tokens and zero tokenholders have been affected by any exploit or incident.
Not applicable; no token-affecting incident has required remediation. Preventive posture for completeness: the token contract is immutable with no mint or pause functions, treasury custody sits behind a 3-of-5 multisig, and vesting custody runs through audited Sablier streaming contracts.
No open, ongoing, or historical token-affecting incidents exist as of 2026-08-25.
Provide a single income statement, expense summary, or comparable operating statement for the primary Foundation or Developer Company. A consolidated or entity-level presentation is acceptable. Balance Sheet and Statement of Cash Flows may be included but are not required. This item is intended to provide transparency into offchain operating resources and expenditures only.
Response
This Token Transparency Filing is provided for general informational purposes only. Blockworks reviews completeness only and does not verify or warrant the accuracy of individual answers. Turtle is solely responsible for the content, accuracy, and legality of its disclosures.
0 |
0 |
6 |
0 |
36 |
1 |
No |
Pre-Seed, Seed, Strategic and Anchor LP rounds; 6-month cliff then 36-month linear vesting streamed via Sablier. Source: docs.turtle.xyz/transparency (B-2 filing, April 2026) |
TURTLE | 2025-10-22 | Team, Advisors & Contributors | Insiders | 0.231 | 231000000 | 0 | 0 | 12 | 0 | 36 | 1 | No | Grants under the Turtle Master Token Incentive Plan (TMTIP); 12-month cliff then 36-month linear vesting via Sablier; tokens cannot be staked or voted until vested and claimed. Source: docs.turtle.xyz/transparency (B-2 filing, April 2026) |
TURTLE | 2025-10-22 | Airdrop | Community | 0.121 | 121000000 | 0.0747 | 74700000 | 0 | 0 | 0 | 0 | Conditional | Genesis airdrop claimable at TGE (74.7M, consistent with the disclosed 154.7M circulating at TGE); remainder distributed in subsequent airdrops per published airdrop rules, no cliff. Source: docs.turtle.xyz/transparency (B-2 filing, April 2026) |
TURTLE | 2025-10-22 | Liquidity, MM & Exchange Reserves | Liquidity | 0.08 | 80000000 | 1.0 | 80000000 | 0 | 0 | 0 | 0 | Yes | Reserve funding market maker token loans and exchange liquidity; 100% unlocked at TGE and treated as circulating from TGE. Source: docs.turtle.xyz/transparency (B-2 filing, April 2026) |
Strategic and institutional partnerships (6,000,000 TURTLE): market maker introductions, exchange relationships, and institutional outreach.
Technical and infrastructure advisory (5,000,000 TURTLE): multi-chain architecture design, security reviews, and infrastructure scaling.
Legal and regulatory advisory (5,000,000 TURTLE): DAO legal structuring, compliance frameworks, and regulatory advisory.
Advisor vesting is formally aligned with the team schedule: 12-month cliff from TGE, 36-month linear vesting thereafter, streamed via Sablier. Advisory grants are compensation for verified ongoing services under the TMTIP's eligibility rules; one-time or lump-sum unlocked advisory payments are prohibited.
0x2e0355922EF3a5b77d29287C808aEafB4e7f25B2 |
Gnosis Safe multisig, 3-of-5 threshold (core team members and independent parties) |
Governor Contract | Deployed for on-chain governance; not yet active | Ethereum | 0x27cbB991EfF5E5c7b6734675E837EDDF924Ffece | OpenZeppelin Governor; sTURTLE token-weighted voting once activated |
Rewards & Distribution Contract | Automated distribution of rewards and emissions; served as the genesis airdrop claim contract at TGE | BSC | 0x56aa6D651bfefA9207B35E508716466359BAe8eF | Owned by the DAO Treasury Multisig (3-of-5) |
Staking Contract (sTURTLE) | TURTLE staking; sTURTLE carries governance voting power | Ethereum | 0x2d362158034EEB28e1a7062F24FfC436b1D01858 | Upgradeable proxy governed by an on-chain access manager |
TURTLE Token Contract | Immutable ERC-20, fixed supply of 1,000,000,000; no mint function, no pause role, no admin key | Ethereum & BSC (same address) | 0x66fd8de541c0594b4dccdfc13bf3a390e50d3afd | Immutable contract; no administrative authority exists |
CCIP Bridge Pool (Ethereum) | Lock-and-mint pool enabling cross-chain TURTLE transfers | Ethereum | 0xd3bd7db2b40dbee54ca70a34921fde8a8d2f8bbb | Chainlink CCIP protocol; Turtle holds no unilateral bridge authority |
CCIP Bridge Pool (BSC) | Lock-and-mint pool enabling cross-chain TURTLE transfers | BSC | 0x4559605e3003fda8c059e14af4f16ba9a004335a | Chainlink CCIP protocol; Turtle holds no unilateral bridge authority |
CCIP Bridge Pool (Linea) | Lock-and-mint pool enabling cross-chain TURTLE transfers | Linea | 0x7263bc9f9d2f94e9a3bcb3efb40c79c43ac0c647 | Chainlink CCIP protocol; Turtle holds no unilateral bridge authority |
Investor & Contributor Vesting Wallet | Funds and creates every Sablier vesting stream for the Private Rounds and the Team, Advisors & Contributors allocations; holds tokens awaiting streaming and receives residual tokens when a stream is cancelled under the TMTIP leaver provisions. The 2,000,000 TURTLE repurchased from one advisor returned to this wallet on 4 September 2026 when that advisor's stream was cancelled, and is retained here. | Ethereum | 0x74adb5972F13Af86ae5e911437b5f077CCc38E5C | Utila MPC custody wallet held by the Turtle Club Association (approval threshold 3 of the 4 authorised approvers, as disclosed in Section 4(e)); sole sender of all TURTLE Sablier streams and the only address able to cancel them |
Sablier Lockup (vesting escrow) | Escrows the vesting TURTLE for the Private Rounds (275M) and Team, Advisors & Contributors (231M) allocations, including the 13,000,000 TURTLE of advisor grants outstanding; releases tokens to recipients per each stream's schedule | Ethereum | 0x93b37Bd5B6b278373217333Ac30D7E74c85fBDCB | Sablier Lockup protocol contract, non-upgradeable, no Turtle admin key; streams cancellable only by the Investor & Contributor Vesting Wallet above, solely under the TMTIP leaver provisions; recipients withdraw vested tokens directly |
Gate | None; no token allocation supplied or committed for listing | No listing lockup, liquidity program, or incentive program applies; the listing was facilitated through the market maker relationships disclosed in Section 12, with no separate listing agreement | None |
MEXC | None; no token allocation supplied or committed for listing | No listing lockup, liquidity program, or incentive program applies; the listing was facilitated through the market maker relationships disclosed in Section 12, with no separate listing agreement | None |
Policy controller: protocol-owned liquidity is a treasury asset of Turtle.Club Association. Any change to the POL strategy, including adding to, rebalancing or withdrawing the position, requires DAO governance approval and is executed by the Board of Turtle.Club Association under Articles 12 and 23 of its Articles of Association, through the 3-of-5 DAO Treasury Multisig. No standing mandate or discretionary authority to alter the position exists.
Unwind and exit policy: there is no time-based or automatic unwind schedule. The position is held to support continuous onchain liquidity for TURTLE. Any withdrawal or unwind would be a treasury action requiring the same governance approval and execution path described above.
No liquidity deals or purchased TVL exist. Turtle has not entered into any arrangement to purchase, rent, or otherwise acquire TVL, and no capital participates in the protocol under any such deal.
No token-secured loans or credit lines exist, including against unissued tokens. Neither the Association, the DevCo, nor any affiliated entity has borrowed against TURTLE, and no unissued supply is pledged as collateral.
Foundation: resources cover legal and compliance, treasury management, infrastructure, and contributor engagement. Contributor token compensation flows under the TMTIP (12-month cliff, 36-month linear, Sablier-streamed); advisor compensation flows from the 16M TURTLE Advisor Allocation. The Association also funds the operating costs of its Lunar Strategy business unit (marketing and go-to-market, not a separate legal entity) under the same budget process, and receives that unit's client revenue.
DAO: treasury resources fund ecosystem growth distributions (subject to 7-day advance public disclosure of recipient category, amount, vesting, and rationale), campaign incentives, and the Association's operating budget. No resources flow to equity holders, and no distributions flow to token holders.
Lab/DevCo: not applicable; no such entity exists.
DAO: (1) DAO Treasury Multisig on Etherscan, https://etherscan.io/address/0x2e0355922EF3a5b77d29287C808aEafB4e7f25B2, and on BscScan, https://bscscan.com/address/0x2e0355922EF3a5b77d29287C808aEafB4e7f25B2: every treasury holding, inflow and outflow, including protocol fee receipts and governance-approved distributions. (2) Treasury dashboard, https://app.turtle.xyz/treasury: real-time view of current holdings, historical inflows and expense outflows across the labeled treasury wallets. (3) Governor contract, https://etherscan.io/address/0x27cbB991EfF5E5c7b6734675E837EDDF924Ffece: on-chain governance parameters (deployed, not yet active). (4) Staking contract, https://etherscan.io/address/0x2d362158034EEB28e1a7062F24FfC436b1D01858: sTURTLE staking balances that carry voting power. (5) Rewards distribution contract, https://bscscan.com/address/0x56aa6D651bfefA9207B35E508716466359BAe8eF: reward and airdrop claim events. (6) Airdrop claims dashboard, https://dune.com/3lixbt/turtle-airdrop-1-claims, and the per-address allocation list, https://github.com/turtle-dao/turtle-transparency: genesis airdrop distribution and claims.
Foundation (Turtle Club Association): (1) Transparency documentation and quarterly reports, https://docs.turtle.xyz/transparency: treasury position, inflows, operating expenses (including the Association's operating budget), token supply and vesting changes, and protocol metrics, published within 30 days of quarter-end; also hosts the Turtle Master Token Incentive Plan governing contributor and advisor vesting. (2) Contract and wallet registry, https://docs.turtle.xyz/token/contracts: canonical list of token, staking, bridge and treasury addresses. (3) Vesting for team, advisors and investors is executed through Sablier streaming contracts on Ethereum; individual stream addresses are published on the contract registry page above as streams are deployed, and each stream is viewable at https://app.sablier.com.
Lab/DevCo: not applicable; no such entity exists, so no dashboards or reports apply.
Not applicable; no incident reports exist. Token contract and treasury addresses are independently verifiable at the explorer links provided in the Labelled Wallets section.
